San Onofre: Nuclear watchdog's legal brief charges reactor restart plan is in breach of license
Posted Jan. 11, 2013 / Posted by: Becca Connors
Experts: No proof that running plant at reduced power is safe
WASHINGTON, D.C. -- Friends of the Earth filed a brief today with the Nuclear Regulatory Commission’s Atomic Safety and Licensing Board panel charging that Southern California Edison’s controversial plan to restart one of the crippled San Onofre reactors would be a breach of the utility’s operating license if approved. Friends of the Earth asserted that Edison cannot be allowed to restart reactor Unit 2 without a formal relicensing review which provides for public adjudicatory hearings.
The filing included affidavits from two independent nuclear engineers who said Edison’s scheme to run reactor Unit 2 at partial power over a trial period is an unproven experiment that will not solve the problems that led to a radiation leak from San Onofre’s Unit 3 steam generator tubes almost one year ago.
“Edison’s experimental plan to restart a badly broken reactor and see what happens is unacceptable,” said Damon Moglen, climate and energy director for Friends of the Earth. “Edison simply cannot prove that if it operates San Onofre under the terms of its restart plan, more steam generator tubes will not fail. This reckless plan would risk the lives and livelihoods of millions of Southern Californians.”
The filing is the opening salvo in a legal process ordered by the NRC commissioners to assess the agency’s response to a Friends of the Earth petition calling for Edison’s restart proposal to undergo a license amendment review. Friends of the Earth argues that the defective steam generators are simply too damaged to meet the terms of San Onofre’s current license. Edison has also failed to prove that its restart plan would not result in an unacceptable increase in risks and consequences of malfunctions or accidents.
In a separate proceeding, the NRC’s Petition Review Board is deciding whether, as Friends of the Earth’s initial petition also charges, Edison should have undergone a license amendment review before installing replacement steam generators between 2009 and 2011. Friends of the Earth’s first meeting with the NRC in that case will be on January 16.
Edison installed the new steam generators at an expected cost to ratepayers of $670 million. The radically redesigned steam generators should have operated for decades, but they have rapidly deteriorated in less than two years as thousands of tightly packed tubes were thinned and damaged by rattling and clashing with each other. Edison’s assessment has thus far failed to establish what is responsible for creating the fluid conditions that are degrading the tubes and support structures.
In expert technical affidavits filed with the NRC ASLB Board, two independent nuclear engineers, John Large of Large & Associates, London and Arnie Gundersen of Fairewinds Associates, Vermont, disputed Edison’s claim that operating Unit 2 at 70 percent power would be safe:
"The extensive and rapid rates of tube wear experienced at both San Onofre reactors are unique. In an attempt to show that reactor unit 2 is safe to restart, Edison has provided analysis, assessments and projections, much of which has never been done before," said Large, a former nuclear industry research engineer known internationally for his work on nuclear safety. "Its assertion that reducing power to 70 percent guarantees the elimination of the major nuclear safety issues arising from the severe tube wear is largely a hypothesis – in any other engineering venture Edison’s approach would be considered experimental, too risky and highly inappropriate."
Edison is expected to submit its response to Friends of the Earth’s brief to the ASLB on January 30.
To view the non-proprietary legal brief: http://libcloud.s3.amazonaws.com/93/a5/d/2681/Opening_Brief_for_Petitioner-NON-PROPRIETARY.pdf
To view the technical affidavit of Arnie Gunderson: http://libcloud.s3.amazonaws.com/93/b5/f/2677/2013_1_11_FOE_Gundersen_Affidavit_reEdisonSanOnofreRSG.pdf
To view Arnie Gunderson's CV: http://libcloud.s3.amazonaws.com/93/9d/8/2679/CV_ArnoldGundersen2012_December.pdf
Hirsch report: http://libcloud.s3.amazonaws.com/93/7e/2/2682/Attachment_3_Hirsch_Report.pdf
Petition to intervene: http://libcloud.s3.amazonaws.com/93/3d/9/2683/Attachment_4_Petition_to_Intervene.pdf
Damon Moglen, Friends of the Earth, (202) 222-0708, firstname.lastname@example.org
Bill Walker, (510) 759-9911, email@example.com
John Large, ++44 208 317 2860
Climate and Energy,
San Onofre News
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